TraceLink Privacy Policy

Effective Date: 1 January 2020

Your privacy is important to us. This Privacy Policy (the “Policy”) explains what personal information TraceLink collects from you through our interactions with you, including through our website (the “Website”) and your use of our web-based services (the “Services”), and how we use that information. The amount of information we collect and how we use it differs depending on whether you establish an account with us for the use of our Services and become a TraceLink Licensee or TraceLink Member.

We may modify the Policy from time to time. We will post the modified Policy on our Website before the changes are effective as described in more detail later in the Policy. We encourage you to look to our Website periodically to see if we have changed the Policy.

This Policy does not apply to any third party applications or software that integrate with the Services or any other third party products, services or businesses. Certain pages of our Website may, from time to time, contain external links. You should verify and validate any and all privacy practices of other websites. We encourage you not to provide personal information without first assuring yourself of the privacy policies of such other websites.

We have organized our Policy into the following sections for your ease of reference:

Personal Information We Collect

How We Use Personal Information

Why We Share Personal Information

How You Can Control Your Personal Information

How We Store and Process Your Personal Information

Why We Retain Personal Information

Accessing, Changing and Deleting Your Personal Information

Children’s Online Privacy Protection

Changes to this Policy

How to Contact Us

PERSONAL INFORMATION WE COLLECT

TraceLink collects information to operate effectively, create an efficient experience for you, and to provide you with our Services if you are a TraceLink Licensee or Member.

You have choices about the personal information we collect from you, and in some cases, you can modify your privacy settings to prevent collection. We describe those options in this Policy.

(1) Information we collect from you. You provide some personal information when you become a TraceLink Licensee or TraceLink Member. When you are asked to provide personal information, you may decline. If you choose not to provide personal information that is necessary for TraceLink to provide the Services, you may not be able to use the Services. Personal information we collect from you includes:

Name and contact information. First and last name, email address, postal address, phone number, and other similar data.

Credentials. Passwords, password hints, and similar security information used for authentication and account access.

Payment data. If you are in a jurisdiction where we accept payments by check, we will record your check number and the amount, and we will retain the check according to our document retention policy. However, most payments are made by wire transfer or Electronic Funds Transfer in which case we do not collect any personal information.

We also collect information you provide to us and the content of messages you send to us, such as questions and information you provide to us for customer or trade partner support. When you contact our support personnel by phone or through chat sessions, we monitor and record those conversations for quality assurance purposes. We maintain personal information you disclose if you use a bulletin board or directory, import a blog, or participate in a chat room. Third parties can read, collect, and use your information to send you unsolicited messages, and TraceLink is not responsible if you choose to disclose your information on these forums. Refer to the “How You Can Control Your Information” section if you want us to delete this information.

(2) Information we collect using cookies and web beacons. TraceLink collects some information by using cookies and similar technologies. Cookies are data files that TraceLink.com (the “Website”) sends to your computer while you are viewing the Website. We collect some information through cookies if you visit the Website regardless of whether you are a TraceLink Licensee or TraceLink Member, including data about your device and how you and your device interact with the Website. If you are a TraceLink Licensee or a TraceLink Member, we also collect data about how you access or use the Services. We record the information we collect on log files. This log data includes the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, as applicable, browser type and settings, the date and time you used the Services, information about browser configuration and plugins, language preferences and cookie data to analyze the trends, administer the Website, track visitor's movements and to improve our Website and our Services. We collect information about devices you use to access the Services, including the type of device, the operating system, device settings, application IDs, unique device identifiers and crash data. The amount of device information we collect varies on the type of device you use.

Third-party advertisers and other organizations may use their own cookies to collect information about your activities on our website and/or the advertisements you have clicked on. This information may be used by them to serve advertisements that they believe are most likely to be of interest to you based on content you have viewed. Third-party advertisers may also use this information to measure the effectiveness of their advertisements. We do not control these cookies and to disable or reject third-party cookies, please refer to the relevant third party's website.

You can set your computer to warn you each time a cookie is sent or turn o_ all cookies through your web browser (e.g., Internet Explorer, Chrome, or Firefox). Check your browser HELP menu to learn the correct way to change or update your browser. You can also learn how to control cookies and to delete cookies from your computer at http://www.youronlinechoices.eu/ and http://optout.aboutads.info/. However, restricting cookies will impact the functionality of the Website and the Services.

Some of our web pages contain electronic images called web beacons. Web beacons allow us to count the number of users who have viewed the Website’s pages. In promotional email messages, web beacons allow us to count how many people read them. We do not use web beacons to access your personal information without your consent.

The Website includes social media features, such as Facebook and Twitter links, as well as share buttons or interactive mini-programs. These features collect the user’s IP address, the pages visited on the site or service, and set cookies to enable the features to function properly. Social media features are either hosted by a third party or hosted directly on the Website. Interactions with these features are governed by the privacy notices of the social media companies that provide them.

(3) Information from third parties. We obtain information from third parties. We protect information obtained from third parties according to the practices we describe in this Policy in addition to any restrictions the third party requires. These third party sources vary but may include data brokers from which we purchase demographic data to supplement the data we collect and publicly-available sources.

HOW WE USE PERSONAL INFORMATION

TraceLink uses the information we collect to operate our business, including providing the Services to you, and to send communications to you, including educational and promotional communications about our Services.

(1) Providing and improving our Services.We use information we collect to provide and improve the Services and to perform essential business operations, such as customer support. We also use information to protect the security of our Services, to detect and prevent fraud, and to resolve disputes and enforce our agreements. We use information to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business..

(2) Communications.We use information we collect to communicate with you and to personalize our communications with you. For example, we may contact you by phone or email or other means to discuss your account, update or inquire about a request, tell you if you need to take some action to keep your account active, or to invite you to participate in market research, including but not limited to certain polls and surveys which may be submitted by other TraceLink users. Participation in these surveys or polls is completely voluntary and you therefore have a choice whether to disclose information. We also use the information we collect to send you educational and promotional communications about our Services.

WHY WE SHARE PERSONAL INFORMATION

We may share personal data with our affiliates and subsidiaries. We will also share personal information with vendors or agents working on our behalf for the purposes described in this Policy. In these cases, the vendors and agents must abide by our information privacy and security requirements and are not allowed to use personal information they receive from us for any other purpose. If you do not want us to share your personal information with these third parties, contact us at notices@tracelink.com.

We will also disclose personal information as part of a corporate transaction such as a merger or sale of assets.

We will from time to time retain an independent third party to perform an analysis of the statistical and aggregate data and other information with respect to our Services. Such aggregated information is used to improve the functionality and/or use of our Services and future product offerings.

We will access, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary to:

Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.

Protect our customers. For example, to prevent spam attempts or attempts to defraud users or our Services, or to help prevent the loss of life or serious injury of anyone.

Operate and maintain the security of our Services, including to prevent or to stop an attack on our computer systems or networks.

Protect the rights or property of TraceLink, including enforcing the terms governing the use of our Services.

HOW YOU CAN CONTROL YOUR PERSONAL INFORMATION

You have some choices about TraceLink’s collection and use or you personal information.

(1) Communications preferences.You can choose whether you wish to receive educational or promotional communications from TraceLink by email and telephone. If you receive promotional email from us and would like to opt out, you can do so by following the directions in that message. If you are a TraceLink Licensee or TraceLink Member, these choices do not apply to mandatory service communications sent to a company email distribution list that we do not control and that are part of our Services or surveys or polls or other information communications that have their own unsubscribe method.

If you are a resident of the European Union, we store and process personal information in the United States, and we take steps to ensure our collection and processing complies with this Policy and the requirements of applicable laws. If you are located within the European Union, TraceLink will transfer to and process your personal information in the United States. The same level of protection for your personal information as exists in the country in which reside may not apply. By using the Website you consent to our collection and use of your personal information as described in this Policy and to the transfer and processing of your information. If you are a TraceLink Licensee or TraceLink Member your submission of your personal information through the Website represents your express consent to such transfer and processing.

TraceLink participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]

TraceLink is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. TraceLink complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, TraceLink is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at notices@tracelink.com.

TraceLink retains personal data for as long as necessary to provide the products and fulfill the transactions you requested or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types, actual retention periods may differ. The criteria used to determine the retention periods include:

How long is the personal data needed to provide the products and operate our business?This includes such things as maintaining and improving the performance of our Services, keeping our systems secure, maintaining appropriate business and financial records, and to send educational and promotional information to you about our Services. This is the general rule that establishes the baseline for most data retention periods.

Is the personal data of a sensitive type?If so, a shortened retention period would apply.

Have you provided consent for a longer retention period?If so, we will retain data in accordance with your consent.

Are we subject to a legal, contractual, or similar obligation to retain the data?Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.

ACCESSING, CHANGING AND DELETING YOUR PERSONAL INFORMATION

You may request access to your personal information, request changes to it when it is incorrect, request us to delete it, or object to TraceLink’s processing of your personal information. If you have consented to TraceLink processing your personal information, you may withdraw your consent at any time. The withdrawal of your consent will not have any effect on the lawfulness of TraceLink’s processing of your information prior to your withdrawal.

Upon request, TraceLink will provide you with information about whether we hold any personal information about you. You can access and review your data preferences and update them by logging into your account on the TraceLink Website or visiting the TraceLink Subscription Management Center.

If you request deletion of information we will respond within a reasonable timeframe. If you are a TraceLink Licensee or TraceLink Member, we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing Services. If you close your TraceLink account, we will remove your personal information unless we reasonably believe that it may be necessary to prevent fraud or abuse; it is retained for legitimate business purposes (such as analysis of aggregated, non-personally identifiable information for account recovery purposes); or, if it is required by law. Even after we have processed your request for a change or deletion, TraceLink may retain certain residual information in the backup and/or archival copies of TraceLink’s database for audit purposes, for our customers’ protection, and to comply with valid legal process. We will retain the audit trail information for at least as long as is required for the subject electronic records, and it will be available for agency review and copying.

In some cases, TraceLink may process personal information about individuals on behalf of its clients. TraceLink acknowledges that these individuals also have the right to access their personal information as well as to request corrections to it or to have it deleted. However, when TraceLink has no direct relationship with the individuals whose personal information it processes, individuals who seek access, or who seek to correct, or delete their personal information, TraceLink will direct them to the relevant TraceLink client (the data controller).

CHILDREN'S ONLINE PRIVACY PROTECTION

Children are not eligible to use TraceLink’s Services. Minors should not submit any personal information to TraceLink and/or use the TraceLink Services. TraceLink does not knowingly collect personal information from minors who are under 18 years of age. If we discover data connected to minors under 13 years of age, we will delete such data immediately.

CHANGES TO THIS NOTICE

We will update this privacy statement when necessary. When we post changes to this Policy, we will revise the “last updated” date at the top of the Policy. If there are material changes to the Policy or in how TraceLink will use your personal data, we will prominently post on the Website the revised Policy and a summary of the changes before they take effect. We encourage you to periodically review this Policy to learn how TraceLink is protecting your information and to access the Website to determine if there are any changes to this Policy.

HOW TO CONTACT US

Unless otherwise indicated, TraceLink is a data controller for personal information we collect through our Services. Our address is TraceLink, Inc., 400 Riverpark Drive, Suite 200, North Reading, Massachusetts 01864. Our telephone number is 781-914-4900. You can also send us an email to notices@tracelink.com.